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CAS 2024 A 10325 (CAS)

Why it matters

This award clarifies the strict criteria for establishing sporting succession in football, requiring evidence that a new club intentionally continues the identity and activities of the old club. It reinforces that mere common ownership or opportunistic creation of a new entity does not trigger liability for the predecessor's debts, protecting clubs from automatic succession claims.

Summary

Sony Norde, a Haitian professional footballer, played for Melaka United FC (Old Club) in Malaysia under contracts from 2020 to 2022. The Old Club failed to pay his salaries, and in December 2022 Norde filed a claim with FIFA's Dispute Resolution Chamber (DRC). The DRC ordered the Old Club to pay USD 100,000 plus interest. However, the Old Club had lost its license to play in the Malaysia Super League due to financial issues and was effectively defunct. Meanwhile, the Melaka United Soccer Association (MUSA), which had been a minority shareholder in the Old Club, incorporated a new club, Melaka FC (New Club), in November 2022 to compete in the amateur M3 League. Norde sought to hold the New Club liable as the sporting successor of the Old Club under Article 21(4) of the FIFA Disciplinary Code. The FIFA Administration rejected this claim, and Norde appealed to the Court of Arbitration for Sport (CAS). The CAS Sole Arbitrator dismissed the appeal, finding that the New Club was not the sporting successor. Key factors included: the New Club did not acquire the Old Club's license, assets, name, colours, logo, website, or a substantial number of players or staff; it was created from scratch and independently obtained its own license; and there was no evidence that the New Club intended to be perceived as a continuation of the Old Club. The Arbitrator emphasized that sporting succession requires a deliberate effort to benefit from the predecessor's goodwill, which was absent here. The decision upholds the principle that a new entity is not automatically liable for old debts simply because it was created by the same association.

The detail

Parties: Sony Norde v. FIFA & Melaka FC

Case number: CAS 2024 A 10325

Outcome: Appeal dismissed; FIFA Administration decision confirmed; Melaka FC not liable as sporting successor.

Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), FIFA Disciplinary Code (FDC), Swiss law

Issues in play: The concept of sporting succession under Article 21(4) FDC and the principle cuius commoda, eius et incommoda (he who enjoys the benefit must bear the burden) were central. The dispute turned on whether Melaka FC was a continuation of Melaka United FC, inheriting its debts.

Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗

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